Biometric data

Data protection glossary · 1 minute read

Biometric data is data resulting from specific technical processing relating to physical, physiological or behavioural characteristics which allows or confirms the unique identification of a person.

Examples

Typical biometric data includes fingerprints, facial geometry, iris and vein patterns and voice or typing behaviour, provided they are analysed by technical means.

An ordinary photograph is not automatically biometric data. It only becomes biometric data when it is processed using specific technical means, for example by facial recognition software.

Where biometric data is processed for the purpose of unique identification, it belongs to the special categories of personal data. Processing is then only permitted under the conditions of Art. 9(2) GDPR, often only with explicit consent.

In the employment context, for example for time recording by fingerprint, particular restraint is called for, as less intrusive means are usually available.

Art. 4(14) GDPR
Definition of biometric data.
Art. 9(1) GDPR
Biometric data for unique identification as a special category.
Recital 51 GDPR
Photographs are only biometric data if processed through specific technical means.

Last updated: September 2026

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Dr. Georg Schröder, LL.M. · Managing Director, Lawyer, Data Protection Officer

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